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The United States Court of Appeals for the Eighth Circuit has explained that the imposition of severe penalties, especially a felony conviction, for the commission of a morally innocent act may violate due process. The elimination of a mens rea requirement does not violate the Due Process Clause for a public welfare offense where the penalty is relatively small, the conviction does not gravely damage the defendant's reputation, and congressional intent supports the imposition of the penalty.
Austin "Jack" DeCoster and Peter DeCoster both pled guilty, as "responsible corporate officers" of Quality Egg, LLC, to misdemeanor violations of 21 U.S.C. § 331(a) for introducing eggs that had been adulterated with salmonella enteritidis into interstate commerce. The district court1Link to the text of the note sentenced Jack and Peter to three months imprisonment. The DeCosters appealed, arguing that their prison sentences and 21 U.S.C. § 333(a)(1) were unconstitutional, and claiming in the alternative that their prison sentences were procedurally and substantively unreasonable.
Were the prison sentences of the DeCosters unconstitutional and unreasonable?
The court held that the DeCosters unsuccessfully argued that their prison sentences were unconstitutional because they did not personally commit wrongful acts. Neither claimed to have been powerless to prevent the company from violating the Food Drug & Cosmetic Act. The court further held that the DeCosters were liable for negligently failing to prevent the salmonella outbreak. More importantly, the court found that the DeCosters’ prison sentences did not violate the Due Process Clause, even though mens rea was not an element of their misdemeanor offenses. Moreover, the three-month prison sentences did not violate the Eighth Amendment as they were not grossly disproportionate to the gravity of their misdemeanor offenses. The sentences were not procedurally and substantively unreasonable.